IRCCourt RulingsNov 30, 2006related by meaning
so. Despite the fact
that Mrs. Colombell received no tax benefit whatsoever from her
“participation” in Inova’s retirement plan, the Court is not free to rewrite the law. See, e.g., Hildebrand v. Commissioner
, 683
F.2d 57, 59 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Johnson v.
Commissioner
, 661 F.2d 53, 54-55 (5th …
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
IRCCourt RulingsApr 2, 2018
…yer worked or
works for the payor".7
6Bot v. Commissioner, 118 T.C. 138, 145 (2002), afCd, 353 F.3d 595 (8th
Cir. 2003).
7Jackson v. Commissioner, 108 T.C. at 135 (quoting Milligan v.
(continued...)
- 10 -
In Peterson we found that "[t]he Mary Kay distributions were 'tied to' the
quantity and quality of Mrs. Peterson's…
IRCCourt RulingsAug 13, 1987related by meaning
alty was designed to cover the situation involved herein. Because of such doubt, we think it judicious to resolve this issue in favor of the taxpayer. Finally, we must decide whether additions to tax pursuant to section 6653(a)(1) and (a)(2) should be imposed. Section 6653(a)(1) provides for an addition to tax of 5 per…
IRCCourt RulingsMay 19, 1994related by meaning
and offered the administrative record from the declaratory judgment case, which has been received as part of the record in this deficiency proceeding. Section references are to the Internal Revenue Code in effect for the periods under consideration. Rule references are to this Court’s Rules of Practice and Procedure.
T…
IRCCourt RulingsMay 11, 1970related by meaning
n after October 31, 1951, from 65 to 55⅛
The trust instrument as amended on or prior to November 15,1955, further provides:
SECTION III
Contributions: A. As and when a participant shall elect to continue as a participant, or as and when an eligible employee who is not a participant shall elect to become a participant, …
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
IRCCourt RulingsMar 5, 2018related by meaning
1, 933 (2d Cir. 1932), rev'g 22 B.T.A. 1171
(1931)), aKg T.C. Memo. 1982-209.
With that admonition in mind, we resolve these cases on their particular facts, applying the text of the relevant Code provisions. For the reasons discussed
below, we reject petitioners' broadest argument--that the substance doctrines have
no…
IRCCourt RulingsMay 4, 1978
… 9,100.00
1970 . 14,325.00 8,925.00
1971 . 32,967.03 24,692.04
1972 . 36,167.03 24,182.97
1973 . 32,595.30 24,795.30
It paid dividends totaling $520 to minority shareholders in both its fiscal years 1972 and 1973.
Ma-Tran’s corporate income tax returns for fiscal years 1972 and 1973 were prepared by William Gryder, a c…
IRCCourt RulingsMar 24, 1980
…016.12 85,640.68 107,788
Total 398,246.00 651,577.32 942,047.46 1,185,666 989,516
Profit-sharing 58,595.30 96,206.43 139,191.71 175,510 146,153
Total 456,841.30 747,783.75 1,081,239.17 1,361,176 1,135,749
Andrew J. Homer
Salary $12,000.00 $12,000.00 $12,000.00 $12,000 $12,000
Commission 44,519.40 73,769.90 106,750.85 1…
IRCCourt RulingsFeb 14, 1996related by meaning
er 8,250-8,250
IRA-1st Fla. 2,500 2,500 -
IRA-1st Fla. 5,000 5,000 -
401-K Plan 45,000 45,000 -
Condo 185,000-185,000
Industrial Bldg. 107,500-107,500 Industrial Bldg. 260,000-260,000
Industrial Vacant 65,000 65,000 -
Stock - HSSTC 59,200 59,200 -
Prestige 23,500-23,500
Breck 25,000 25,000 -
West Coast 25,000 25,000 -
…
IRCCourt RulingsMay 9, 1988
…d Retirement Fund v. Commissioner, T.C. Memo. 1982-594, and Wenzel v. Commissioner, T.C. Memo. 1982-595, affd. on consolidated appeal Wenzel v. Commissioner, 707 F.2d 694 (2d Cir. 1983).
Loftus v. Commissioner, 90 T.C. 845 (1988), concerned the request for a determination only as it related to the Brewery Workers Fund.
IRCCourt RulingsMay 4, 2004related by meaning
ners are liable for the 10percent additional tax on the $55,555 early distribution that
petitioner received from the plan.
2
To reflect the foregoing, Decision will be entered
for respondent
.
IRCCourt RulingsSep 26, 2001related by meaning
effect, rewrite
the statute to achieve what seems to be a more equitable result.
See Eanes v. Commissioner
, supra
at 171. “Whether and to what
- 6 - extent deductions shall be allowed depends upon legislative
grace; and only as there is clear provision therefor can any
particular deduction be allowed.” New Colonial Ic…
IRCCourt RulingsAug 4, 1983related by meaning
ven if the income was attributable primarily to personal services. If capital is material, as it is here, the statutory 30-percent limitation applies. As explained in note 7, supra, Congress, in the Revenue Act of 1978, amended section 1348, effective for taxable years beginning after December 31,1978, to remove this m…
IRCCourt RulingsJun 14, 2012related by meaning
t higher contributions, section 4973(a) imposes for each taxable year an
excise tax of 6% for excess coritributions, computed on the lesser of (1) the amount of the exceså contribution, and (2) the value of the account as of the end of
the taxable year. The tax appliës eách year until the excess contributions are
elimi…
IRCCourt RulingsAug 13, 1990
…iency Sec. 6651(a)(1) Sec. 6651(a)(2)
12/31/80 $1,524 $383 $381
12/31/81 4,211 947 2,000
12/31/82 6,595 1,484 2,803
12/31/83 8,972 2,019 3,275
12/31/84 11,242 2,529 3,428
12/31/85 13,619 2,451 2,723
Respondent also determined a deficiency in second-tier tax under sec. 4975(b) of $286,911.
Robert C. Slaton
Docket No. 39…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.
VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
IRCCourt RulingsJul 30, 1985related by meaning
the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
87 FR 26806 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests IRCProposed Rules (FR)Proposed May 5, 2022
…74.83
2
99,341.16
39
96,915.25
76
67,044.59
3
99,313.80
40
96,761.20
77
64,773.93
4
99,292.72
41
96,595.51
78
62,366.05
5
99,276.45
42
96,416.30
79
59,795.50
6
99,261.55
43
96,220.61
80
57,080.84
7
99,248.33
44
96,005.41
81
54,213.71
8
99,236.50
45
95,768.60
82
51,205.27
9
99,226.09
46
95,509.98
83
48,059.88
10
99,217.…